UPSC MainsLAW-PAPER-II201720 Marks
Q8.

When, under the law of torts even using reasonable care, is a person liable for the tort of negligence? Discuss.

How to Approach

This question requires a nuanced understanding of the tort of negligence, moving beyond the basic elements of duty, breach, and damage. The focus is on situations where reasonable care is taken, yet harm still occurs. The answer should explore concepts like ‘strict liability’, ‘absolute duty’, ‘inherently dangerous activities’, and ‘acts of God’. A structured approach involving defining negligence, outlining standard care, then detailing exceptions where liability arises despite reasonable care, with illustrative case laws, is recommended.

Model Answer

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Introduction

The tort of negligence is a cornerstone of civil law, providing redress for harm caused by a failure to exercise reasonable care. Generally, establishing negligence requires proving a duty of care, a breach of that duty, causation, and resulting damage. However, the law recognizes situations where even the exercise of reasonable care does not absolve a person from liability. This arises primarily when the activity undertaken is inherently dangerous, or a statute imposes absolute liability, or when the risk is so high that reasonable care is insufficient to avoid it. This discussion will delve into these exceptions, exploring the legal principles and precedents that govern such scenarios.

Understanding Negligence and Reasonable Care

Negligence, in its simplest form, is the breach of a legal duty to take care which results in harm to another. The standard of care expected is that of a ‘reasonable man’ – a hypothetical person exercising ordinary prudence and foresight. This standard is objective, meaning it doesn’t consider the individual’s subjective beliefs or capabilities. Establishing negligence typically involves proving all four elements: duty, breach, causation (res ipsa loquitur – the thing speaks for itself), and damages.

Exceptions to the Reasonable Care Rule: When Liability Arises

Despite exercising all reasonable care, a person can still be held liable for negligence under certain circumstances. These exceptions are rooted in public policy considerations, recognizing that some activities pose such inherent risks that those undertaking them must bear the responsibility for any resulting harm.

1. Strict Liability (Rule in Rylands v Fletcher)

The landmark case of Rylands v Fletcher (1868) LR 3 HL 330 established the principle of strict liability. This rule states that a person who brings onto their land something likely to do mischief if it escapes, must keep it in at their peril. This means liability arises regardless of whether reasonable care was taken. The key elements are:

  • Bringing a dangerous thing onto land
  • Likelihood of mischief if it escapes
  • Escape of the dangerous thing
  • Resulting damage

Example: Storing large quantities of water in a reservoir. If the reservoir bursts despite all reasonable precautions, the owner is strictly liable for the resulting damage.

2. Inherently Dangerous Activities

Certain activities are considered so inherently dangerous that undertaking them implies an acceptance of strict liability. These activities are often those that involve a high degree of risk, even when conducted with utmost care. Examples include:

  • Blasting operations
  • Handling explosives
  • Keeping wild animals
  • Manufacturing hazardous substances

In these cases, the law places the burden of risk on the party profiting from the activity.

3. Absolute Duty

In some situations, the law imposes an absolute duty to ensure safety, meaning any failure, even without negligence, results in liability. This often arises in statutory contexts.

Example: The Public Liability Insurance Act, 1991 imposes absolute liability on industries dealing with hazardous substances. Any accident involving such substances triggers liability, irrespective of whether reasonable care was taken. This was a direct response to the Bhopal Gas Tragedy (1984), which highlighted the inadequacy of the existing legal framework.

4. Vicarious Liability – Independent Contractors

Generally, a principal is not liable for the negligence of an independent contractor. However, exceptions exist where the work is inherently dangerous, or the principal has retained control over the manner in which the work is performed. In such cases, the principal may be held liable even if they exercised reasonable care in selecting a competent contractor.

5. Res Ipsa Loquitur – The Thing Speaks for Itself

This doctrine applies when the accident is of a kind which does not ordinarily occur in the absence of negligence. It allows a plaintiff to establish negligence without direct evidence, relying on the inference that negligence must have occurred. However, it doesn’t automatically establish liability; the defendant can rebut the inference by demonstrating they exercised reasonable care.

6. Acts of God (Vis Major)

While not strictly an exception to reasonable care, the defense of ‘Act of God’ can absolve a party from liability if the damage was caused by an unforeseen and extraordinary natural event, which could not have been prevented by reasonable care. However, the event must be truly exceptional and not merely a foreseeable risk.

Conclusion

In conclusion, while the standard of reasonable care is central to the tort of negligence, the law recognizes that certain activities and circumstances warrant a higher degree of responsibility. Strict liability, absolute duty, and the inherent dangers associated with specific undertakings can all lead to liability even when reasonable care is exercised. These exceptions reflect a balancing act between protecting individual rights and ensuring public safety, acknowledging that some risks are simply too great to be borne by those who may be harmed. The evolving legal landscape continues to refine these principles, particularly in the context of emerging technologies and industrial hazards.

Answer Length

This is a comprehensive model answer for learning purposes and may exceed the word limit. In the exam, always adhere to the prescribed word count.

Additional Resources

Key Definitions

Res Ipsa Loquitur
A doctrine that allows a plaintiff to establish negligence based on the inference that negligence must have occurred, even without direct evidence, when the accident is of a kind that doesn't ordinarily happen without negligence.
Vicarious Liability
A legal doctrine that holds one party liable for the actions of another, even if the first party was not directly involved in the act causing harm. This often applies in employer-employee relationships.

Key Statistics

According to the National Crime Records Bureau (NCRB), India reported 4.7 lakh accidental deaths in 2021, highlighting the prevalence of incidents where negligence may be a factor. (Source: NCRB, 2021)

Source: NCRB, 2021

According to a 2020 report by the World Health Organization, road traffic accidents cause approximately 1.3 million deaths globally each year, many of which could be attributed to negligence. (Source: WHO, 2020)

Source: WHO, 2020

Examples

Bhopal Gas Tragedy

The Bhopal Gas Tragedy (1984) serves as a stark example of strict liability. Union Carbide, despite claiming to have followed safety protocols, was held liable for the gas leak due to the inherently dangerous nature of the chemicals stored at the plant.

Frequently Asked Questions

What is the difference between strict liability and absolute liability?

Strict liability allows for some defenses (like contributory negligence), while absolute liability, as established in the MC Mehta v. Union of India case, does not allow for any defenses. Absolute liability imposes a higher standard of responsibility.

Topics Covered

LawCivil LawTortsNegligenceDuty of Care